Alinea Capital


Privacy policy

Here you will find information on how Alinea Capital collects and uses personal information:

General

Alinea Capital Management AS (“the Company” or “Alinea”) has formed this privacy policy based on the European Union Directive General Data Protection Regulation EU 2016: 679 (“GDPR”) and The Personal Data Act (“PuL”). The GDPR directive entered into force on 25 May 2018 throughout the EU. The purpose of this regulation is to ensure the security and confidentiality of personal data and privacy of EU citizens.

The Company

Alinea Capital Management AS is registered in Norway with main office in Olav Vs gate 5, 0161 Oslo, Norway. Org. nr. 923 266 879. For inquiries regarding our privacy policy of your personal information, contact us via privacy@alineacapital.no

What is considered personal data?

As per article 4 of the GDPR, personal data is any information relating to an identified or identifiable natural person (data subject); an identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Personal data we could obtain from third party sources

Any publicly available personal data that has been shared via a public platform such as Twitter, LinkedIn, etc. (i.e., employment details etc.), your contact details.

How do we collect the above information?

If you are a source of collection, we usually gather the data via:

If we have obtained your personal data from third parties, we usually collect the data via one or more of the following:

How we use your data/purposes of processing

To fulfil our contractual obligations with you, to verify your identity to provide you with ongoing communication & business opportunities, for crime and fraud prevention, detection, and related purposes, to enable us to manage customer/client service interactions with you; and where we have a legal right or duty to use or disclose your information (for example in relation to an investigation by a public authority or in a legal dispute, etc.). To exercise our legal rights (for example in court cases). To make our services available to you

Sharing data with third parties:

Our service providers, Following your request or with your written or tacit consent, we may share your personal data with some or all the following:

International sharing of the personal data?

As we do business internationally, we could share your information with any relevant country for business based on two considerations:

  1. In order to meet our statutory and legal obligations.
  2. In order to fulfil contractual obligations.

Under the GDPR, an international transfer of data may be made where:

If none of the above apply, such transfers are permitted only where the transfer:

is not repetitive (similar transfers are not made on a regular basis); involves data related to only a limited number of individuals; is necessary for the purposes of the compelling legitimate interests of the Company (provided such interests are not overridden by the interests of the individual); and is made subject to suitable safeguards put in place by the Company (in the light of an assessment of all the circumstances surrounding the transfer) to protect the personal data.

In these cases, we would be obliged to inform the relevant supervisory authority of the transfer and provide additional information to you.

Lawful basis of processing:

If you are a person entering into a contract or terms of business with us by either:

How long do we keep your data?

We do not retain any more of your personal information than we believe is necessary for any of the purposes outlined above and we do not retain your personal information for any longer than is reasonably necessary to do so for the purpose set out in this notice. We will retain your information for:

How do we protect your data?

Alinea is committed to put in place security measures to ensure your data security:

Confidentiality – the data can be accessed, altered, disclosed or deleted only by those you have authorised to do so (and that those people only act within the scope of the authority you give them); Secure – data is stored on password protected systems Integrity – the data we hold is accurate and complete in relation to why are we processing it; and Availability – the data remains accessible and usable, i.e. if personal data is accidentally lost, altered or destroyed, we can recover it and therefore prevent any damage or distress to the individuals concerned.

You have the following rights:

the right to be informed, hence this privacy notice gives the right to ask for a copy of personal data that we hold about you (the right of access); the right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you (the right of rectification); the right to erasure, also known as the ‘right to be forgotten’. This is not applicable to data held under the lawful basis of ‘legal obligation’ or if processing is necessary for the establishment, exercise, or defence of legal claims; The right to object the processing of your personal data. So, you can object processing based on legitimate interests or direct marketing (in the last case we must stop as soon as we receive your objection).

You have the right to opt out of receiving promotional communications at any time, by:

Notifying Alinea that you want to unsubscribe via the contact channels set out in this Policy.

The right to restrict processing, so you can limit the use of your data, but only applies in certain circumstances.

If you wish to exercise any of the above rights, please contact us by email to privacy@alineacapital.no

For questions regarding the processing of personal data, customers are welcome to contact the company. If you believe there has been committed errors in handling of personal data, you can file a complaint privacy@alineacapital.no, or directly to the Swedish Authority for Privacy Protection: so@imy.se.